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What the CMS Federal IDR data shows
- Volume: 2,559,375 disputes were initiated across the four quarters of 2025 (2025-Q1: 545,422; 2025-Q2: 641,390; 2025-Q3: 653,445; 2025-Q4: 719,118).
- Outcomes: the provider side prevailed in 83.8% of payment determinations in 2025-Q4, down from 88.2% at the 2025 high. In 13.2% of 2025-Q4 determinations only one party submitted an offer and paid fees.
- Multiples: the median prevailing offer was 334% of QPA for emergency department services and 522% for items with a QPA under $100, versus 169% at $10,000 or more.
- Who files: the ten largest initiating parties or representatives filed 67% of out-of-network disputes in 2025-Q4; 37% of initiations were from practices with 50 or fewer employees.
- Fees: CMS collected $143,077,600 in administrative fees and certified IDR entities received $304,845,511 in compensation in 2025-Q4.
Explore the detail: benchmarks, QPA bands, states and who files.
Source: CMS Federal IDR Supplemental Tables, reporting year 2025 (CMS reports page). Quarterly medians cannot be combined into a yearly median, so each quarter is shown separately.